9 replies to this topic

[carine]

hi all:

i'm developing Hazard Analysis for raw material used in our process.. and i got stucked in analysis potential chemical hazard in our packaging material which is plastic bag. Can i just put" no perceived hazard" since food grade plastic was used OR put" present chemical residue" in chemical potential hazard column.. which one more suitable..Appreciated if someone help me out on this..

[Jasna Lasinger]

Hi

You will be surprised to find out how thorough chemical assessment of potential hazards should be. There are specific regulations for food contact materials in different countries. Few examples are bellow:

• EU Regulation 10/2011/EC specifies 10mg/dm2 as the max. overall migration (OML). When applicable, SML (Specific Migration Limits) must be determined - processing aid/'impurity of "technical support agent"/catalyst may contain one or more substances that have SML (see regulation 10/2011/EC). Supplier should also verify that article, manufactured according to GMP, does not modify the organoleptic properties of the food.
• There are number of additional EEC National Legislations that food contact article / material must comply with: UK ("The Plastic Materials and Articles in Contact with Food (England)2009, Statutory Instrument 2009 n. 205); Spain (Real Decreto N.118 31/01/2003 modified by real Decreto N.103/2009 of 06/03/2009); ..
• EU Directive 94/62/EC (as amended 2001) < 100 ppm for total incidental cadmium, chromium (VI), lead and mercury - the product has the potential to be recycled
• US FDA 21 CFR 177. 1520 Olefin Polymers; 21 CFR 178,210 Antioxidants and Stabilizers; 21 CFR 178.3297 Colorants for Polymers; 21 CFP 178.2620 Mineral Oils, 21 CFR 176. 170 see Table 2 - list of chemicals that can be used for all food types,.... .

I have recently found out that our food grade polypropylene supplier is using tallow derived additives sourced from bovine material. I have requested additive specifications. The supplier only indicated that animal material is sourced from the US and Canada and can be any party of the animal. It raised concern about presence of Bovine Spongiform Encephalophaty (BSE) and Transmissible Spongiform Encephalopathy (TSE) "Mad Cow" and/ or their prions. Countries are graded from BSE/TSE Free (e.g. Australia) to high risk country (e.g. UK). Body parts used are also considered when assessing potential hazard (e.g. use of brain and spine tissue has very high risk). Supplier has been deleted and blacklisted and alternative supplier was approved based on the requested testings results performed by GLP certified laboratories.

I hope this can help.

Cheers from Western Australia

[carine]

Is plastic bag present chemical residue naturally OR leaking out when food had kept inside the plastic bag??

[foodsafety2008]

Hi,

Absolutely correct and I agree the above details . So You have to sure about chemical hazard also should be taken in while doing the risk analysis for the HACCP system.

Regards,

[Bag man]

Hi Carine

I think the first question is "What sort of plastic are you talking about?" EG polythene; polyprop, laminate.
If its food grade plastic it should be basically inert.

However, speak to your packaging provider and obtain specifications and a certificate of migration to ensure that the packaging does not present a hazard to user or consumer safety and meets all statutory requirements.
If your provider is BRC certificated this shouldn't be a problem. I imagine they will have a generic document (Declaration of compliance) to state that migration levels from the packaging are within accepatable limits.

Create a table of physical, chemical and biological hazards and include the packaging and the controls you put in place.

Then include these specs and certificates in your annual hazard analysis review and/or management review to the the effect that you have considered whether or not the packaging could be hazardous if there were a critical defect.

If there could be any significant chemical migration, ask yourself whether you are using the correct type of plastic!!!

Good luck.
John.

[carine]

Can i say there is " no perceived hazard" at plastic bag chemical hazard analysis as long as i can proved our supplier using food grade resin to manufacture the plastic bag??

[Charles.C]

Can i say there is " no perceived hazard" at plastic bag chemical hazard analysis as long as i can proved our supplier using food grade resin to manufacture the plastic bag??

Dear Carine,

It probably depends on exactly whose requirements you are trying to satisfy.

In many locations there are appropriate legislatory requirements / forms relating to yr question which include some of items as previously mentioned, eg migration data. If so, any potential buyer / reseller of your product will logically also be required to conform accordingly, ie get them from you.

Rgds / Charles.C

PS (added) - IMEX, serious end-buyers normally require 2 sets documents - (a) something like Food grade resin evidence from 1st stage, (b) migration data etc from 2nd stage.

A basic haccp plan may be typically formulated by stating bags are manufacturer-declared food grade. The full details are then related to validation/verification/supplier approval.

[Mendeljev]

I was thinking on the fact if this plastic is coloured or not ? We use only blue bags so that of there is a physical contamination, this can be noticed easier then transparent plastics

[john123]

Can i say there is " no perceived hazard" at plastic bag chemical hazard analysis as long as i can proved our supplier using food grade resin to manufacture the plastic bag??

If you're going to the extent to prove the supplier uses the proper resins to manufacture the bag, isn't that a perceived hazard? Our hazard analysis identifies "non-food grade product" as one of the hazards for packaging supplies, and our preventative measure is a statement from the manufacturer that the package is, in fact, food grade and is intended for the type of material we are packaging. If you say "no perceived hazard" and have no preventative measure, then for all an auditor knows you might be packaging your product into used grocery bags.

(last part there intended to be humorous)

[john123]

I was thinking on the fact if this plastic is coloured or not ? We use only blue bags so that of there is a physical contamination, this can be noticed easier then transparent plastics

We're a 3rd party operation and 99.9% of our customers provide their own packaging. That said, before I started here our customer called us with a stop production order during a run one time because of their liners. They're a bright pink color, and the customer learned the pink coloring is made from some sort of crustacean. The customer needed us to stop production until they received a statement from the manufacturer that the colored part of the liner is sandwhiched between two layers of clear plastic that are not a risk to their product. But it modified the practice we use for that customer, and anytime a liner is torn, the product and liner must be disposed of. That's my experience with colored liners.